Comment Analysis · Docket FS-2025-0001

FS-2025-0001-414745

Opposes rescissionA3 weakSubstance 9/24Owed an answerPosted September 15, 2026 On Regulations.gov

In short: The comment places on the record specific geographic locations (Gila National Forest, Two Medicine area) and scientific evidence (Kilbride et al. 2026, Short 2017) demonstrating that the agency's justification for rescinding the Roadless Rule based on wildfire reduction is unsupported, while citing specific 2025-2026 budget and staffing cuts (Rose 2026) to argue the agency lacks capacity for management.

Scored directly — The comment's whole text was scored on its own.

Scorecard

Each dimension is scored 0–3; the eight sum to the substance score out of 24.

  • Specific placeNames a specific location — from a region down to an exact creek, trail, road, or map reference.
  • Local knowledgeDraws on a first-hand connection to the place — visits, sustained activity, occupation, or a professional role.
  • EA analysisEngages the agency's environmental analysis directly.
  • Analytical gapIdentifies something the analysis fails to address.
  • EvidenceBacks claims with specific facts, data, or research.
  • RequestMakes a specific, actionable request of the agency.
  • AlternativeProposes a different course of action.
  • LegalCites statutes, regulations, or legal obligations.

How hard it is to set aside

A3 weak: Substantive, but easier to set aside.

Owed an answer on Evidence.

Standard dismissals it defeats

  • Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
  • Outside the scope The agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.

Still open to the agency

  • Alternative already eliminated The agency says it considered and eliminated the alternative the comment proposes, with a reason. Cannot be defeated from the comment text alone.
  • Already addressed The agency says its analysis already covers the point. Defeated when the comment cites the law itself: there is no analysis to cite against a statutory claim.
  • Deferred to a later decision The agency says the point belongs to a later, site-specific decision. Cannot be defeated from the comment text alone.
  • Not required The agency says the analysis the comment asks for is not required. Cannot be defeated from the comment text alone.
  • Preference noted The agency notes the comment as a statement of preference and takes no action on it. Cannot be defeated from the comment text alone.
  • No cause and effect shown The agency says the comment asserts a harm without showing how the action causes it. Defeated when the comment shows the mechanism.
  • Certified not substantive The agency certifies the comment raises nothing substantive. Defeated when the comment alleges illegality, which is substantive by the definition the certification runs on.

Topics

  • Environmental Protection Biodiversity
    • “protected nearly 60 million acres of undeveloped forest land”
    • “habitats for countless species”
    • “devastate these precious environments”
    • “protect these ecosystems and ensure their conservation”
  • Forest Management Wildfire
    • “roads through forested areas do not correspond with a significant reduction in wildfires”
    • “vast majority of wildfires (85%) are started directly or indirectly by human activity”
    • “best way to address fire risk is by taking climate change seriously”
    • “guarantees corporate exploitation of our natural resources”
  • Climate Carbon Storage
    • “taking climate change seriously”
    • “prioritizing climate action”
    • “investing in clean energy technology”
    • “funding public transportation to cut down on emissions”
  • Recreation Tourism Public Use
    • “experience and enjoy some of these incredible forest areas”
    • “spend time in areas such as the Gila National Forest”
    • “Two Medicine area near Glacier National Park”
    • “breathtaking our country is”

What it names

National Forests
Gila National Forest
Works cited
10.1111/csp2.7041110.2737/rds-2013-0009.4

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapEvidenceLegal

Dear Lawmakers, I am writing to express my vehement opposition to rescinding the 2001 Roadless Area Conservation Rule. The Roadless Rule has always been widely supported by the American people, from individual recreationists to environmental activism groups to tribal governments to state governing bodies. In the 25 years that the Roadless Rule has been in effect, it has directly protected nearly 60 million acres of undeveloped forest land, including old growth trees and habitats for countless species. Repealing this law would have terrible and far-reaching consequences for the environment and all life that calls these protected lands home. In the proposal to rescind the Roadless Rule, the Trump administration has cited reduction of wildfires as the primary driver. However, research such as a 2026 meta analysis of wildfire data across the Western United States (Killbride, et al., 2026), shows that roads through forested areas do not correspond with a significant reduction in wildfires. In fact, as supported by USDA research (Short, 2017), the vast majority of wildfires (85%) are started directly or indirectly by human activity. Opening protected forest land to development increases human contact, placing these forests at risk for fires originating from human activity. While I am also extremely concerned about the long and devastating wildfires in recent years, the best way to address fire risk is by taking climate change seriously and using legislation to support environmental stewardship. Instead of sacrificing our precious forest land, we should be prioritizing climate action, including investing in clean energy technology, funding public transportation to cut down on emissions, and heavily regulating the environmental impact of large corporations on an industrial level. The proposal also states that repealing the Roadless Rule will help manage forest land. However, this seems directly at odds with the dramatic cuts made to the Forest Service in 2025 and 2026 (Rose, 2026). With 6,000 employees terminated in 2025 alone and millions of dollars slashed in a 75% reduction to the Forest Service budget, the United States government already lacks the necessary resources to properly manage forest land. Eliminating the Roadless Rule under such circumstances guarantees corporate exploitation of our natural resources. Finally, on a personal level, I’ve been able to experience and enjoy some of these incredible forest areas across several states. Being able to spend time in areas such as the Gila National Forest near Silver City, New Mexico, and Two Medicine area near Glacier National Park has shown me firsthand how breathtaking our country is. Opening these areas up to roads, developers, logging, and mining will devastate these precious environments. I urge you to choose to uphold the 2001 Roadless Area Conservation Rule to protect these ecosystems and ensure their conservation for generations of Americans to come. Sincerely, Johanna Monson Geerts Citations Kilbride, J. B., Johnston, J. D., Kennedy, R. E., Meigs, G. W., & Francis, E. M. (2026). Roadless status under the Roadless Area Conservation Rule is not associated with increased wildfire in the US National Forest System. Conservation Science and Practice, e70411. https://doi.org/10.1111/csp2.70411 Short, Karen C. 2017. Spatial wildfire occurrence data for the United States, 1992-2015 [FPA_FOD_20170508]. 4th Edition. Fort Collins, CO: Forest Service Research Data Archive. https://doi.org/10.2737/RDS-2013-0009.4 Rose, G. (2026, June 12). The hollowing of the forest service. nrdc.org. https://www.nrdc.org/media/hollowing-forest-service

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